Interstate or foreign transmission

AND · 18usc1343:interstate

The charged transmission must satisfy the jurisdictional requirement. Identify evidence of interstate routing, not simply the presence of a computer or telephone.

Exact element source

in interstate or foreign commerce
Source: docroot/ir/usc/title18.jsonl#title18_sec1343; Unicode character offsets [324:357] (end exclusive); SHA-256 944569d18f6d3624ae87dde151ee823f6cf078faa69c6d3e59fb832bc1aaa933.

Routes and case patterns

Curated routes and observed case patterns
RouteDefinitionMerits instance blocksDistinct merits casesExamples (up to 3 cases per count group)
Unclassified route
provisional; 6 observed cases
no definition yet0
Satisfied 0; not satisfied 0; excluded context 6
0

Used only in non-merits blocks (6).

Excluded context examples:

United States v. Jefferson — 562 F. Supp. 2d 719 (2008) · United States District Court for the Eastern District of Virginia · 2008 — not reached · basis not recorded (18usc1343: author: Fable · not independently reviewed) · applied/merits · not counted
Pattern: not recorded

United States v. Sancho — 957 F. Supp. 39 (1997) · United States District Court for the Southern District of New York · 1997 — not reached · basis not recorded (18usc1343: author: Fable · not independently reviewed) · applied/merits · not counted
Pattern: not recorded

New England Data Services, Inc. v. Becher — 829 F.2d 286 (1987) · United States Court of Appeals for the First Circuit · 1987 — not reached · basis not recorded (18usc1343: author: Fable · not independently reviewed) · background/merits · not counted
Pattern: not recorded

_whole
accepted; provisional (1 case)
The element is decided as a whole: the reasoning turns on no narrower doctrinal sub-question that distinguishes it from any other application of this element.1
Satisfied 1; not satisfied 0; excluded context 0
1

United States v. Boliaux — 915 F.3d 493 (2019) · United States Court of Appeals for the Seventh Circuit · 2019 — satisfied · proved (18usc1343: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) · applied/merits · counted
Pattern: payments from an Illinois dealership routed through Pennsylvania or Ohio

How courts decided this element

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
United States v. Jefferson — 562 F. Supp. 2d 719 (2008) · United States District Court for the Eastern District of Virginia · 2008 — not reached (18usc1343: author: Fable · not independently reviewed)Interstate or foreign transmissionnot_reached
Excluded from merits counts
applied / merits

Unspecified routeNo source quotation recorded for this block.
United States v. Sancho — 957 F. Supp. 39 (1997) · United States District Court for the Southern District of New York · 1997 — not reached (18usc1343: author: Fable · not independently reviewed)Interstate or foreign transmissionnot_reached
Excluded from merits counts
applied / merits

Unspecified routeNo source quotation recorded for this block.
New England Data Services, Inc. v. Becher — 829 F.2d 286 (1987) · United States Court of Appeals for the First Circuit · 1987 — not reached (18usc1343: author: Fable · not independently reviewed)Interstate or foreign transmissionnot_reached
Excluded from merits counts
background / merits

The court infers only that interstate communication was probable (one defendant incorporated in another state); left to discovery on remand.
Unspecified routeNo source quotation recorded for this block.
United States v. Hasson — 333 F.3d 1264 (2003) · United States Court of Appeals for the Eleventh Circuit · 2003 — not reached (18usc1343: author: Fable · not independently reviewed)Interstate or foreign transmissionnot_reached
Excluded from merits counts
applied / merits

Michigan-to-Florida bank transfers; the interstate character of the charged wires was not contested (the fact sits in the `wire` block).
Unspecified routeNo source quotation recorded for this block.
United States v. Brumley — 59 F.3d 517 (1995) · United States Court of Appeals for the Fifth Circuit · 1995 — not reached (18usc1343: author: Fable · not independently reviewed)Interstate or foreign transmissionnot_reached
Excluded from merits counts
applied / merits

That the agents' calls to the Missouri computer actually crossed state lines is recited as the only interstate communication in the record and was not disputed; what failed was the defendant's foreseeability of that interstate leg, recorded under `wire`.
Unspecified routeNo source quotation recorded for this block.
United States v. Boliaux — 915 F.3d 493 (2019) · United States Court of Appeals for the Seventh Circuit · 2019 — satisfied · proved (18usc1343: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Interstate or foreign transmissionsatisfied
Counted merits instance
applied / merits

basis: proved; party: Edward Boliaux; count: four counts of wire fraud (used-car dealership floorplan-financing scheme); subject: party=Edward Boliaux; count=four counts of wire fraud (used-car dealership floorplan-financing scheme)

Recited in the adopted Rule 29 order; the opinion does not indicate that interstate routing was contested on appeal, and there is no separate deciding sentence.
payments from an Illinois dealership routed through Pennsylvania or Ohio
The charged wire transmissions traveled across state lines-from Joliet Motors in Illinois and routed through Pennsylvania or Ohio
Source: docroot/ir/caselaw/f3d_915.jsonl#/f3d/915/0493-01; Unicode character offsets [3650:3779] (end exclusive); SHA-256 a2d8cc2afe88a91fa856e6f1d0d7fefd9cfc2de1338b80b4342b6d9644d0e078.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

United States v. Baker — 923 F.3d 390 (2019) · United States Court of Appeals for the Fifth Circuit · 2019 — not reached (18usc1343: author: Fable · historical QA: FIX (QA2, neov2/qa/wave2-cases-QA2.md) · changed after review; current content not independently reviewed)Interstate or foreign transmissionnot_reached
Excluded from merits counts
applied / merits

Only glimpse: a footnote quoting the case agent that the Count 5 email between two people in Texas was routed through company servers in California; not an issue on appeal.
Unspecified routeNo source quotation recorded for this block.

Court interpretations

interpretation

The charged wire transmissions traveled across state lines-from Joliet Motors in Illinois and routed through Pennsylvania or Ohio, and they advanced the scheme to defraud the lenders because they were payments for a vehicle that had been sold to the detriment of the lender's interests.

United States v. Boliaux — 915 F.3d 493 (2019) · United States Court of Appeals for the Seventh Circuit · 2019 (18usc1343: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))

The charged wire transmissions traveled across state lines-from Joliet Motors in Illinois and routed through Pennsylvania or Ohio, and they advanced the scheme to defraud the lenders because they were payments for a vehicle that had been sold to the detriment of the lender's interests.
Source: docroot/ir/caselaw/f3d_915.jsonl#/f3d/915/0493-01; Unicode character offsets [3650:3936] (end exclusive); SHA-256 a2d8cc2afe88a91fa856e6f1d0d7fefd9cfc2de1338b80b4342b6d9644d0e078.

The charged transmission must satisfy the jurisdictional requirement. Identify evidence of interstate routing, not simply the presence of a computer or telephone.